Arbit Each Way Pty Ltd (t/a SULKY) Privacy Policy
This is the privacy policy (Privacy Policy) of Arbit Each Way Pty Ltd (ACN 116 475 408) (SULKY). Arbit Each Way Pty Ltd is an organisation that is covered by the Privacy Act 1988 (Cth) (Privacy Act) and must comply with the Australian Privacy Principles (APPs) contained in the Privacy Act.
This Privacy Policy explains how the application/website Sulky.APP will manage your personal information and the personal information of your beneficial owners, agents or related third parties, which we collect as a result of you becoming a customer of Sulky.APP, your use of SULKY websites and any pages, websites and applications (together the Website) that are owned and/or operated by Arbit Each Way Pty Ltd or whenever you otherwise deal with Arbit Each Way Pty Ltd.
In this Privacy Policy, personal information (as defined in the Privacy Act) means information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.
This Privacy Policy explains how we manage your personal information, including:
- the kinds of personal information we collect and hold;
- how we collect and hold your personal information;
- how you may access your personal information held by us and have it corrected;
- how you may complain about the way we deal with your personal information, and how we will deal with your complaint;
- whether we will disclose your personal information to overseas recipients.
Website use
In using the Website you agree to be bound by the terms of this Privacy Policy. Arbit Each Way Pty Ltd may review the Privacy Policy periodically and reserves the right to change the Privacy Policy at any time at its discretion. A new version of the Privacy Policy will be available on Sulky.APP Website and it will apply to all of your personal information held by us at the time. By continuing to use the Website, you agree to these changes.
The kinds of personal information collected
SULKY only collects personal information for purposes which are directly related to its functions or activities, and only when it is necessary for, or directly related to, such purposes.
Opening a Sulky Account
To open a SULKY Account, we require the following personal information from you:
- contact details (i.e. name and email address);
- preferences that you have submitted (i.e. preferred username, marketing opt-in/out);
Purchasing a Subscription Service
To purchase a subscription from SULKY, we require the following additional personal information from you:
- financial information (i.e. credit card details). It is noted that financial information is not stored by SULKY. This information is collected, tokenised and then processed externally via 3rd Party payment service providers. SULKY will link to said external payment providers where payment information will be requested and utilised for the purposes of payment only. SULKY does not have any access to that information.
Allowing you to use our Services
We collect the following activity information from you when you engage with our Website or otherwise use our services:
- information about the devices used to access our products and services;
- the channel from which you accessed the Website;
- your responses to promotions, functions, giveaways, competitions and surveys;
- information about your utilisation and activity on our Website;
Sensitive information
SULKY will not collect sensitive information such as racial or ethnic origins, political opinions, criminal record, health information, religious and spiritual beliefs and sexual preferences or practices unless required by law (i.e. to maintain the integrity of our products and services and to maintain security).
Collection purposes
SULKY will collect your personal information in order to:
- set-up an account with us and to allow you to access and make use of our Website;
- allow you to participate in the products and services offered;
- administer your account;
- maintain our accounts and records;
- monitor Website usage levels and the quality of the service we provide;
- inform you, from time-to-time, about products and services that we consider may interest you and for related purposes;
- create aggregate data about customers through demographic profiling and statistical analysis of the database for market research and developing our products and services;
- market and advertise SULKY's offers and promotions;
- enable our related bodies corporate to market their products and services directly to you;
- enable third party business partners and sponsors to market their products and services to you from time-to-time;
- enable you to order SULKY merchandise (including via online merchandise stores);
- liaise with relevant financial institutions;
- send to you, from time to time, surveys and questionnaires;
How will SULKY collect and hold personal information
SULKY will collect your personal information by any of the following methods:
- directly from the individual via electronic account registration;
- from our records of how you use and access SULKY's products and services;
If you choose not to provide certain information about yourself, we may not be able to provide you with the products or services, or the level of service, with which we pride ourselves.
Cookies
SULKY uses "cookies" in order to provide you with a seamless experience. Cookies are pieces of data sent by a website to your device and stored on the internal hard drive. They allow the website/application to identify and interact with your device.
SULKY and its Related Bodies Corporate
We may collect and disclose personal information to our related bodies corporate to:
- comply with the law, regulations and licence conditions applying to them;
- send you marketing material directly;
How SULKY will hold your personal information
SULKY may store your information in hard copy or electronic format, or in storage facilities that we own and operate, or are owned and operated by third party service providers under contract.
Direct marketing and opting out
When registering an account with SULKY, you may choose to receive promotional or marketing information from SULKY (and its related bodies corporate) by selecting the appropriate option on the registration page. By opting-in to receive direct marketing material, SULKY (and its related bodies corporate), may use your personal information to inform you about products or services or about promotional activities which SULKY believes may be of interest or of benefit to you. SULKY (and its related bodies corporate) may do this via email, SMS, MMS, telephone, mail or any other form of electronic or internet communication.
If you no longer wish to receive marketing or promotional material from SULKY at all or in any particular form, you may:
- simply select to opt-out (i.e. unsubscribe) of receiving any further marketing material at the bottom of the page of the marketing communication you have received;
Note, we may also contact you in relation to the management and administration of your SULKY account and provide you with service updates or announcements. These communications may occur via any of the modes of contact outlined above. Customers that have elected to opt-out of direct marketing communications will continue to receive service announcements, until such time that the customer informs SULKY that it does not wish to receive these communications (this includes periods you are no longer using our products and services).
Disclosure of personal information
SULKY will not share your personal information with other organisations or anyone else unless the disclosure is for one of the purposes outlined above. Accordingly, SULKY may disclose your personal information to the following third parties:
- an authorised representative;
- SULKY's related bodies corporate;
- SULKY's business partners and sponsors who may have offers of interest for you from time-to-time;
- financial institutions;
- external providers of services we use to operate our business and manage our business systems (i.e. advertising agencies, mailing houses, merchandise stores and providers, printers, call centres, IT consultants, market research analyst and providers of payment processing and identify verification services);
- law enforcement bodies;
SULKY will take all reasonable steps to ensure that any personal information which SULKY discloses to a third party is protected by that party in accordance with the Privacy Act and under contractual arrangements.
Security of personal information
SULKY takes steps to protect the personal information it holds against loss, interference, unauthorised access, use, modification or disclosure and against other misuse. These steps include password protection for electronic files, securing paper files in locked cabinets and physical access restrictions.
SULKY's employees, agents, contractors and related bodies corporate are required to maintain the confidentiality of customers' personal information. Remember to always log out of your account when you have completed your time on the Website. This is particularly important if you share a computer with another person. You are responsible for the security of and access to your own computer, mobile device or any other handset used to access the Website. Also, you should be aware of the many security risks that exist today and take appropriate care to help safeguard your personal information.
SULKY will keep your personal information until it no longer needs to use it or disclose your personal information for any purpose that is authorised under the Privacy Act or is not legally required to retain that information. SULKY will take reasonable steps to destroy or de-identify the personal information.
Access and correction of personal information
If a customer requests access to the personal information that SULKY holds about them, or requests that it changes that personal information, SULKY will allow access or make the changes unless it considers that there is a sound reason under the Privacy Act or other relevant law to withhold the information. SULKY will endeavour to correct your personal information within 7 days, unless notified otherwise.
If SULKY does not agree to make the requested changes to personal information, you may make a statement about the requested changes and SULKY will attach this to the record.
For further information about how to request access or changes to the personal information held by SULKY, contact details are provided below.
Overseas disclosures
SULKY will only disclose personal information to an overseas recipient if:
- we've taken reasonable steps to ensure the recipient does not breach the Privacy Act;
- contractual arrangements are in place to protect the security of your personal information; or
- the provision of information is required by law or treaty or convention which Australia is a party;
Complaints
SULKY takes its obligations pursuant to the Privacy Act seriously. You may complain about a suspected breach of the APPs by SULKY by submitting your complaint in writing to SULKY's Privacy Manager, using the contact details below.
Any complaint should set out in as much detail as possible, all the relevant particulars relating to the complaint, including the suspected reason behind why SULKY has allegedly breached the APPs.
Upon receiving a written complaint, SULKY will acknowledge receipt of the complaint in writing within 7 days. SULKY will investigate the matters described in the complaint and then provide a substantive written response within 28 days from the date the written complaint was received.
If your complaint is not resolved by the Privacy Manager, you can refer it to the Office of the Australian Information Commissioner (www.oaic.gov.au).
Contact details
Further information in relation to this Privacy Policy, how to lodge a complaint, request the Privacy Policy in a different format or provide any comments, email SULKY at